Thursday, September 28, 2017

What's Wrong with Cell Phone Radiation Exposure Limits?

Last September, the Washington, DC law firm, Swankin & Turner, sent a letter to the Federal Communications Commission (FCC) that questioned whether the agency adequately enforced its cell phone radiation exposure limits.

The letter raised four areas of concern about current testing procedures and posed twelve specific questions.

One concern is that the FCC's two-decade-old cell phone testing procedures allow for a 30% margin of error. This means that a cell phone with a Specific Absorption Rate (SAR) greater than 1.231 W/kg can actually exceed the FCC's exposure limit of 1.6 W/kg. The law firm's clients estimate that about 75% of the cell phones on the market may exceed the current exposure limits.

National and international regulatory
limits for radiofrequency radiation (RFR) exposure from cell phones and cell
towers are outdated according to Dr. Yuri Grigoriev. Moreover, the standards are inadequate to protect human
health, especially the health of children and those who are hypersensitive to
RFR.

Dr. Grigoriev calls for research on the biological effects of
chronic exposure to low-intensity RFR in order to develop stronger RFR standards,
“bearing in mind, above all, long-term exposure on the brain at all levels of
development.” He argues that until we
adopt protective regulations, we should “provide the public with full
information on the possible dangers of mobile communication for their health. “

Finally, he appeals to his colleagues “Do
not sin against the truth!”

Dr. Grigoriev is the Chairman of the Russian National Committee on Non-ionizing Radiation Protection (RNCNIRP), and a member of the International Advisory Committee on Electromagnetic Fields and Health for the World Health Organization.

Following are excerpts from Dr. Grigoriev's book chapter and a link to download the document.

“The ultimate goal of electromagnetic field (EMF) standards
is to protect human health. Exposure limits are intended to protect against
adverse health effects of EMF exposure across the entire frequency range and
modulation.”

“The Russian standard for base stations has already been in
existence for more than 30 years and is more rigid than the maximum level
recommended by the International Commission of Non-Ionizing Radiation
Protection (ICNIRP). This distinction has been discussed at scientific meetings
for many years—unfortunately, without result.

The second EMF source of mobile communication—the mobile
phone—has no sufficient substantiation on exposure limits. The irradiation of a
brain is not limited and is not supervised. The children using mobile phones
are especially at high risk.”

“The first RF EMF standard for the population, SanPiN
848-70, was approved by the Ministry of Health of the USSR in 1970 and was
considered for the population exposure limit of 1 μW/cm²in the microwave band
of 300 MHz to 300 GHz. In 1978, the USSR
Ministry of Health approved the next SanPiN No. 1823-78. In this
document, MPL for the population in the frequency range of 300 MHz to 300 GHz
was set as 5 μW/cm².”

“Currently, three questions remain relevant for
standardization:

1. Are there nonthermal biological effects of low levels of
RF EMF?

2. Is it possible that the irradiation of the population
with RF EMF throughout human life leads to increased adverse biological
effects?

3. Is there a “threshold” level of exposure to RF EMF, and
if so how do we define it?”

“….These results together with numerous studies conducted by
scientists from many countries provide direct evidence that RF EMF intensity of
up to 10 mW/cm²may have a nonthermal mechanism of action.”

“There is evidence that RF EMF can cause development of
tumors in the brain of mobile phone users after a 10–12 year “waiting period”
(Hardell and Calberg, 2009). The term 'heavy users' that appeared in some
publications linked the unfavorable bioeffects of the prolonged mobile phone
use to accumulative processes of adverse biological effects.

It has been shown that after a single exposure to
low-intensity RF EMF, certain changes in the brain EEG occur (Lukyanova, 1999,
2015). During the first hours after exposure, there is a restoration of
bioelectrical activity of the brain, which indicates the insinuation of
compensatory processes. Naturally, in these conditions, a repeated exposure
might weaken compensatory processes and lead to development of the process of
accumulation (Lukyanov et al., 2015).”

“The threshold level is the lowest level of exposure of the
physical factor (EMF RF), below which the risk to public health does not exist,
is introduced in analogy with the principles of ionizing radiation. Given the complexity of this problem, we
propose to determine the threshold level as a criterion for the body’s response
to RF EMF exposure, but on the condition that this response should not be
pathological. This reaction may be compensatory/ adaptive and should exist
within the physiological range.”

“When determining the limit values for base stations, the
RNCNIRP decided to leave the limit value for the general public of 10 μW/cm²
unchanged, as it was set in 1984. This value was well justified by previous
research, and so there was no need for changing it (Vinogradov and Dumanskiy,
1974, 1975; Shandala and Vinogradov, 1982; Shandala et al., 1983, 1985;
Vinogradov and Naumenko, 1986; Vinogradov et al., 1999).

It is important to note that the MPL of 10 μW/cm² for the
population has remained intact for more than 30 years. Previously, the standard
was used only in Russia and the countries formerly in coalition with the Soviet
Union. Now, MPLs of 10 μW/cm² or less are used as RF legal exposure limits or
nonbinding recommendations for national, regional, urban, or sensitive areas
for at least 20 countries worldwide (Figure 15.1).”

“The adoption of the standard in 2003 for the mobile phone
in terms of formalizing requirements for methods of measuring the near field
and for the establishment of a threshold for the evaluation of RF EMF exposure
on brain function as a critical organ was not optimal….There was a proposal to
use a safety factor of 5 and set to the cell phone MPL at 100 μW/cm² (Russian
Standard, 2003—SanPiN 2.1.8/2.2.4.1190-03). It should be emphasized that SanPiN
2.1.8/2.2.4.1190-03, for the first time, introduced the recommendation to limit
cell phone use for persons younger than 18 years as well as pregnant women.”

“The following factors allow us to conclude that the
potential risk to the health of children who use mobile phones is very high:

– Absorption of electromagnetic
energy by the head of a child is much higher than in the head of adults
(children’s brain tissue has a higher conductivity, the size of the child’s
head is smaller, and the skull bone of the child is thin).

– The distance from the antenna to
the brain is short, because the child’s ear shell is very soft and has almost
no layer of the cartilage.

– The child’s body is more
sensitive to EMFs than adults.

– The child’s brain is more vulnerable
to the effects of EMF.

– The brains of children have a
greater propensity to accumulation of adverse reactions in the context of
repeated exposures to EMF.

– EMF RF may have an adverse effect
on cognitive functions.

– Today’s children use mobile
phones at an early age and will continue to use them during their lifespan, and
so the duration of the exposure of children to electromagnetic radiation will
be substantially larger than that of modern adult users.”

“According to the members of the Russian National Committee
of Non-Ionizing Radiation Protection (RNCNIRP, 2008), some possible disorders
that might originate in children who use mobile phones include weakened memory,
decline of attention, reduction of mental
and cognitive abilities, irritability, sleep disturbance, tendency to stress
reactions, and increased epileptic readiness.

It is also possible to expect the development of the adverse
effects in older age as the result of the accumulation of adverse effects both
in cells and in various functional systems of the body: brain tumors, tumors of
the auditory and vestibular nerves (at age 25–30 years), Alzheimer’s disease,
“dementia,” depressive syndrome, and other manifestations of degeneration of
the nervous structures of the brain (at age 50–60 years).

Children users of mobile phones are not able to know that
their brains are subjected to EMF, risking their health. This is a significant
factor in moral ethics for parents. Also
important is that the risk of EMF RF exposure is not less than the risk for
children’s health from tobacco or alcohol.”

“Currently, international standards are developed by ICNIRP,
IEEE, CENELEC, and other international and national commissions. Their
methodology uses only the results of experimental animal studies obtained under
the conditions of acute effects and thermal-level EMF RF (Bernhard, 1999).

Any standard safety margin depends on the predetermined
threshold. Outside Russia, the threshold level is determined on the basis of
“stable pathological reactions” in the conditions of acute exposure to RF EMF
heat level (WHO Handbook, 2002).”

“Our long experience with ionizing and non-ionizing
radiations led us to formulate the following postulate: “The development of
hygiene standards for the population should take into account the actual
conditions of EMF RF exposure of the population—local or total exposure, acute
single exposure or chronic, constant, or repeated exposure; the functional
importance of ‘critical organ’ or ‘critical body systems’; and effect on all
population groups or only on certain limited groups of the population”
(Grigoriev, 1997, 2008a).

Taking into account this postulate, we can make a clear
conclusion that the Western standards do not meet the basic hygienic
requirements …. Western regulations do not take into account events that
occurred for the first time during the life of our civilization. Children who
use mobile phones voluntarily irradiate their brains. This EMF RF exposure of
the brain occurs every day, and the fractional exposure is projected for many
years.

We criticized the Western standards because they do not
correspond to the actual conditions of RF EMF exposure on the population
(report in 2003 at an international seminar in China, Grigoriev et al.,
2003b).”

“This analysis of the methodology of RF EMF regulation
abroad allows us to conclude that the current so-called International
Recommendations/Guidelines (ICNIRP, 1998) and the IEEE Standards (S95.1-2005),
CENELEC (EN 50166-2.2000) do not correspond to existing conditions of RF EMF exposure
on the population and cannot guarantee the safety of the public health.

Interestingly, this view was confirmed by the European
Parliament in 2009 ….”

“We believe that it is necessary within the framework of the
development problems of the methodology of EMF RF standards to specifically
consider additional criteria for risk assessment related to the exposure of
children to RF EMF who became active users of mobile phones.

Western experts working on new standards, completely
ignoring the problem of childhood cell phone use do not take into account the
WHO opinion on the higher sensitivity of children to environmental factors in
the International standards: ‘children are different from adults.’

Children have a unique vulnerability. As they grow and
develop, there are “windows of susceptibility”: periods when their organs and
systems may be particularly sensitive to the effect of certain environmental
threats (WHO, 2003).”

“The electromagnetic burden on the population is growing
daily. At the same time, over the last 20 years, debates are still continuing
on the following topic: Is the health of the population at risk because of
increasing pollution due to RF EMF from the base stations and mobile phones?

The brains of almost all people on earth are exposed to EMF
radiation. However, practically, there are no restrictions for the use of
mobile communications. Having the advantages and convenience of mobile
communication, the population is ignoring the information about the possible
risks to their health. This threat affects everybody, including children aged
3–4 years. Pregnant women do not protect their fetuses from exposure to EMF.

The scientific community is watching this picture and is
waiting for the results of this uncontrolled global experiment (Markov and
Grigoriev, 2013). We saw similar hazards during the Victorian period in Britain
(wallpaper with mercury and toys with lead).”

“…there are four postulates that show the risk to public health
from mobile communication (Grigoriev, 2013). It is necessary to convince the
population and to create an environment of reasonable restrictions on the use
of this communication.

The first postulate:
‘EMF—harmful type of radiation.’ Mobile communication uses RF EMF. This
type of electromagnetic radiation is considered harmful. Exceeding the
permissible levels can cause disease; therefore, it requires hygienic control.
This is the absolute truth.

The second postulate:
‘The brain and EMF.’ The mobile phone is an open source of EMF, and there
is no protection for valuable human organs. EMFs affect the brain during mobile
phone use. Nerve structures inside the internal ear (the vestibular and the
auditory apparatus) are located directly under the beam of EMF. This is the
absolute truth.

The third postulate: ‘Children
and EMF.’ For the first time, in history the child’s brain is subjected to
RF EMF. There are no results of the study of chronic local RF EMF exposure on
the brain. Children are more vulnerable to external environmental factors. This
opinion was expressed by WHO (2003) and in the Parma Declaration (WHO European Region,
2010). This is the absolute truth.

Fourth postulate: ‘The
lack of adequate recommendations/standards.’ There is no agreement on the
methodology for determining the EMF RF remote control and for the development
of international standards, and there are no results from 20 years of debate on
this issue. This is a real fact.”

“I believe that the time has come to provide the public with
full information on the possible dangers of mobile communication for their
health. The abovementioned four postulates allow the public to comprehend the
likely risks to their health from uncontrolled use of mobile communication.”

“I appeal to
colleagues: Do not sin against the truth!”

Conclusions

“Of course, new sources of electromagnetic radiation are
creating additional problems in the development of standards. Public health
protection issues in connection with the use of mobile communications have
become completely different. The use of mobile phones has led to the local long-term
RF EMF exposure to the brain. The normative level is not considered a permanent
RF EMF exposure on the brain of the user. Existing regulations do not address
to the real hazard RF EMF exposure. Given these circumstances, standards cannot
currently guarantee the well-being of adults and children.

Children mobile phone users were included in the group of
high risk. In this regard, there is a need to develop more appropriate
stringent standards to ensure absolute security for growing children. Existing
standards should take into consideration the vulnerable group of people
hypersensitive to RF EMF.

Given that the current regulations are outdated, it is
necessary to carry out complex research into possible biological effects on
conditions of chronic exposure to low-intensity EMF RF, bearing in mind, above
all, long-term exposure on the brain at all levels of development.

As a temporary measure of limiting exposure to EMF on the
population, it is necessary to introduce the concept of “voluntary risk”; that
is, mobile telephony should be a product of self-selection on the background of
the official public information about possible health hazards.”

In 1996, the Federal Communications Commission (FCC) adopted a cell phone radiation exposure limit based upon a measure called the Specific Absorption Rate or SAR. A SAR testing procedure was developed that is applied to all cell phones sold in the U.S.

In the U.S and about a half dozen other countries, cell phones are allowed to have a maximum SAR of 1.6 watts per kilogram of tissue averaged over one gram of tissue. Many countries, however, adopted a more permissive standard, that was developed by a self-appointed body, known as the International Commission on Non-Ionizing Radiation Protection or ICNIRP. The ICNIRP standard allows for up to 2.0 watts per kilogram of tissue averaged over ten grams of tissue.

Recent studies have determined that the head can absorb 2-3 times the radiation from a phone based on the ICNIRP standard as compared to the U.S. standard. Nonetheless, the cell phone industry in the U.S. has been lobbying the FCC to adopt the ICNIRP standard using the euphemism, "harmonization," to justify this weakening of the regulatory standard.

Considerable research, however, suggests that both the U.S. and ICNIRP standards do not adequately protect us from health risks due to exposure to cell phone radiation. The Specific Absorption Rate (SAR) and testing procedures are based upon four fallacies:

1) The SAR standards assume that a thermal (or heating) effect is the only way that microwave radiation emitted by cell phones can harm tissue.

However, many studies have found that exposure to low-intensity,
microwave radiation at non-thermal levels where there is no measurable
temperature change can produce DNA damage, reactive oxygen species, and stress proteins, and can alter brain activity and open the
blood-brain-barrier. The SAR standards do not protect mobile device users from these non-thermal effects.

2) The standards are based upon averaging cell
phone radiation exposure over one or ten grams of tissue and over time.

However, peak exposures and/or "hot spots" which damage tissue are not considered.

However, chronic effects due to long-term exposure are ignored.4) The SAR test procedure uses a Specific Anthropomorphic Mannequin (SAM) which simulates a very large man's head and body.

The standards do not address exposure to fetuses, children, or
women, different tissue types, or metallic objects worn on
the body that influence the absorption of radiation (e.g., metal eye
glasses, earrings, or dental braces). Research indicates that a child's brain absorbs 2-3 times the radiation of an adult's brain.

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Evaluation of Specific Absorption Rate as a Dosimetric Quantity for Electromagnetic Fields Bioeffects

Purpose To evaluate SAR as a dosimetric quantity for EMF bioeffects, and identify ways for increasing the precision in EMF dosimetry and bioactivity assessment.

Methods We discuss the interaction of man-made electromagnetic waves with biological matter and calculate the energy transferred to a single free ion within a cell. We analyze the physics and biology of SAR and evaluate the methods of its estimation. We discuss the experimentally observed non-linearity between electromagnetic exposure and biological effect.

Results We find that: a) The energy absorbed by living matter during exposure to environmentally accounted EMFs is normally well below the thermal level. b) All existing methods for SAR estimation, especially those based upon tissue conductivity and internal electric field, have serious deficiencies. c) The only method to estimate SAR without large error is by measuring temperature increases within biological tissue, which normally are negligible for environmental EMF intensities, and thus cannot be measured.

Conclusions SAR actually refers to thermal effects, while the vast majority of the recorded biological effects from man-made non-ionizing environmental radiation are non-thermal. Even if SAR could be accurately estimated for a whole tissue, organ, or body, the biological/health effect is determined by tiny amounts of energy/power absorbed by specific biomolecules, which cannot be calculated. Moreover, it depends upon field parameters not taken into account in SAR calculation. Thus, SAR should not be used as the primary dosimetric quantity, but used only as a complementary measure, always reporting the estimating method and the corresponding error. Radiation/field intensity along with additional physical parameters (such as frequency, modulation etc) which can be directly and in any case more accurately measured on the surface of biological tissues, should constitute the primary measure for EMF exposures, in spite of similar uncertainty to predict the biological effect due to non-linearity.http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0062663

Resources

For further information about the FCC review of the SAR exposure limits in the U.S. see ...
FCC Needs Input on Radio Frequency Radiationhttp://bit.ly/19ie1zGDoes The FCC Plan To Rubber Stamp Outdated Cell Phone Radiation Standards?http://bit.ly/19LJlHe